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The Government Accountability Office ("GAO") issued the fourth report in its ongoing series examining ways to make the U.S. Bankruptcy Code ("Code") more effective in resolving certain failed financial companies. The report addressed recent changes to the Code, as well as efforts to improve cross-border coordination to facilitate the liquidation or reorganization of large financial companies under bankruptcy. According to the report, a number of bills that were introduced in the previous Congress would, if reintroduced and passed, make broad changes to the Code that are relevant to financial

The NFA found that the companies' principal, as well as both PAMC and AIM, used misleading promotional material to solicit the public by touting the likelihood of investors achieving dramatic profits, and downplaying the risk of loss by contextualizing it within presentations of large-profit examples. The Complaint also charged PAMC and AIM with failing to maintain required records relating to the promotional material, and PAMC, AIM, and their principal with (i) failing to observe "high standards of commercial honor and just and equitable principles of trade," and (ii) failing to diligently

The MSRB requested the SEC's approval of a proposal to expand the post-trade data displayed on its Electronic Municipal Market Access ("EMMA") Web site. The amendments to MSRB Rule G-14 regarding the Real-Time Transaction Reporting System would require municipal securities dealers to indicate trades that were executed on an alternative trading system and those that involved non-transaction-based compensation arrangements. See: MSRB Rule Filing.

The CFTC held a public roundtable discussion to review system safeguards-testing requirements and to consider how best to leverage enhanced system safeguards-testing requirements. Panelists addressed the need for testing in the current cybersecurity environment, as well as the effectiveness of certain types of system safeguards testing and associated risk assessment practices, including (i) vulnerability and penetration testing, (ii) key controls testing and (iii) business continuity-disaster recovery testing. Panelists expressed concern over the interconnectedness of the financial system, and

Steven Lofchie Commentary by Nihal Patel and Steven Lofchie

Oxfam America Inc. ("Oxfam"), an anti-poverty group, submitted a memorandum in reply to the SEC's summary judgment opposition. In the memorandum, Oxfam asks the U.S. District Court for the District of Massachusetts to reject the SEC's contention that a Dodd-Frank rule requiring oil, gas and mineral companies to report payments to foreign governments would be too complex to finish this year. The Oxfam suit, filed in September 2014, seeks to compel the agency to implement Section 1504 of Dodd-Frank. According to the memorandum, the SEC's argument against the enforcement of the mandate takes two